Archive for the ‘partnership’ Category

It’s been a while since we did a Tax Geek Tuesday, but boy do I have a doozy planned for you today. It delves into partnership tax law, so even before we begin, you can rest assured that the subject matter is needlessly complicated and nearly impossible to communicate in any logical and practical manner.

But that’s never stopped us before; after all, we’ve previously ventured into subchapter K to take on Section 754 adjustments, technical terminations, and even partnership book-ups. So why not take a stab at Section 704(c), an area of the Code that most practitioners ignore until it becomes an immediate and important issue, at which point they have a whoooolllle lot of catching up to do.

What is Section 704(c)? It’s a provision with complex application but a simple goal: to prevent a partner from contributing appreciated property to a partnership and then shifting that pre-contribution gain to a non-contributing partner or partners.

The items in this blog are informational only and are not meant as tax advice. Consult with your tax advisor to determine how any item applies to your situation. A select group of Tax Professionals of WithumSmith+Brown write Double Taxation, and any opinions expressed or implied are not necessarily shared by anyone else at WithumSmith+Brown.

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